MJS AHLUWALIA, Jaipur V. ACIT, Jaipur

ITA 7/JPR/2013

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 5275 (ITAT-JAIPUR)
• Duration Of Justice: 3 year(s) 5 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 03-06-2016
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2008-2009
• Appeal Filed On: 02-01-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: PA R VIHYKFKHZ IZRFKHZ
• Assessee Lawyers: O P AGARWAL CA DH
• Keywords: Search and seizure; Salary income; Deemed dividend
• Section: 143(3); 153A; 263; 132

Judgement Text

VK;DJ VIHYH; VF/KDJ.K] T;IQJ U;K;IHB] T;IQJ IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHE S, JAIPUR JH HKKXPUN] YS[KK LNL; ,OA JH YFYR DQEKJ] U;KF;D LN L; DS LE{K BEFORE: SHRI BHAGCHAND, AM & SHRI LALIET KUMAR, JM VK;DJ VIHY LA-@ ITA NO.O7/JP/13 FU/KZKJ.K O'K Z@ ASSESSMENT YEAR : 2008-09 SHRI MJS AHLUWALIA, 65, GOPAL BARI. JAIPUR CUKE VS. THE ACIT, CIRCLE-2, JAIPUR LFKK;H YS[KK LA-@THVKBZVKJ LA-@ PAN NO. ABYPA 1038 R VIHYKFKHZ@ APPELLANT IZR;FKHZ@ RESPONDENT FU/KZKFJRH DH VKSJ LS@ ASSESSEE BY : SHRI MANISH AGARWAL (C.A.) & SHRI O.P. AGARWAL (CA) JKTLO DH VKSJ LS@ REVENUE BY : SHRI KALIKA SINGH (CIT) LQUOKBZ DH RKJH[K@ DATE OF HEARING : 01.06.2016 ?KKS'K .KK DH RKJH[K @ DATE OF PRONOUNCEMENT : 03/06/2016. VKNS'K@ ORDER PER SHRI LALIET KUMAR, JM THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF LD. CIT(A)-I, JAIPUR DATED 08.11.2012 WHEREIN THE ASSE SSEE HAS TAKEN FOLLOWING GROUNDS OF APPEAL: (1) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) HAS GROSSLY ERRED IN UPHOLDING THE ADDITION OF RS. 23,32,962/- MADE ON ACCOUNT OF DEEMED DIVIDEND U/S 2(22)(E), AR BITRARILY, THUS THE ADDITION DESERVES TO BE DELETED. (2) THAT THE LD. CIT(A) HAS FURTHER ERRED IN NOT AP PRECIATING THE FACT THAT RS. 23,32,962/- WAS GIVEN AS IMPREST ADVANCE T O THE ASSESSEE BY THE COMPANY FOR DISCHARGING HIS OFFICI AL DUTIES AND ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 2 WAS NOT A LOAN THEREFORE THE SAME CANNOT BE HELD AS DEEMED DIVIDEND AS DEFINED U/S 2(22)(E) OF THE I.T. ACT AN D THUS THE ADDITION SO CONFIRMED DESERVES TO BE DELETED. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS AN INDIVIDUAL AND PROMOTER DIRECTOR OF M/S RAJASTHAN MINING ENGIN EERING PVT. LTD. (RMEPL) AS ALSO THE PROPRIETOR OF M/S AHLUWALIA A LLOYS. A SEARCH AND SEIZURE ACTION U/S 132 OF THE INCOME TAX ACT, 1 961 WAS CARRIED OUT ON 12.11.2009 AT THE BUSINESS AND RESIDENTIAL PREMISES OF KAMAL JEET SINGH AHLUWALIA AND GROUP. NOTICE U/S 153A WAS ISSUED. IN RESPONSE TO WHICH, ASSESSEE FILED HIS RETURN OF INC OME DECLARING THE SAME INCOME AS WAS DECLARED IN THE RETURN OF INCOME FILED U/S 139(1) I.E. RS. 1,32,230/- WHICH STOOD FILED ON 24.3.2009 COMPRISING INCOME FROM SALARY, HOUSE PROPERTY & OTHER SOURCES. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, IT WA S OBSERVED BY LD. ASSESSING OFFICER (A0) THAT ASSESSEE WAS HOLDING M ORE THAN 10% SHARES IN M/S REMPL AND THUS DIRECTED THE ASSESSEE TO FILE COPY OF HIS ACCOUNT IN COMPANYS BOOKS. ON PERUSAL OF ACCO UNT, IT WAS FOUND THAT THERE WAS A MAXIMUM OUTSTANDING DEBIT BALANC E OF RS. 36,35,607/- DURING THE YEAR AND THE COMPANYS ACCU MULATED PROFIT INCLUDING NET PROFIT FOR THE YEAR WAS RS. 56,59,893 /-. FURTHER, IT WAS OBSERVED BY LD. AO THAT DURING A.Y. 2004-05, THERE WAS HIGHEST DEBIT BALANCE OF RS. 13,02, 645/-, WHICH WAS TAXED AS DEE MED DIVIDEND U/S 2(22)(E) AND IN ALL SUBSEQUENT YEAR MAXIMUM DEBIT B ALANCE DID NOT ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 3 EXCEED RS. 13,02,645/-. HOWEVER, IN A.Y. 2008-09 T HE DEBIT BALANCE OF ASSESSEES ACCOUNT STOOD AT RS. 36,35,607/- AND THEREFORE, AFTER GIVING BENEFIT OF AMOUNT ALREADY TAXED AS DEEMED DI VIDEND IN A.Y. 2004-05, I.E. RS. 13,02,645/-, BALANCE AMOUNT I.E. 23,42,962/- WAS TAXED IN THE YEAR UNDER APPEAL. IT WAS SUBMITTED BEFORE LD. AO THAT THE SAID SUM WA S OUTSIDE THE PURVIEW OF SECTION 2(22)(E) AS THE MONEY DEBITED I N THE COMPANY A/C WAS IN THE NATURE OF IMPREST MONEY TAKEN IN AD VANCE FOR CONDUCTING THE BUSINESS OF THE COMPANY BY HIM. HOW EVER, EXPLANATION OF THE ASSESSEE WAS NOT ACCEPTED BY TH E LD. AO IN ABSENCE OF SUBMISSION OF EXPENDITURE BILLS. THUS A SSESSMENT WAS COMPLETED MAKING ADDITION OF RS. 23,32,962/-. AGG RIEVED OF THE ORDER OF LD. AO, APPEAL WAS FILED BEFORE THE LD. CI T(A), WHICH WAS REJECTED. THEREFORE, ASSESSEE HAS PREFERRED THIS A PPEAL. 2.1 N THE DATE OF HEARING I.E. ON 01.06.2016 THE L D. AR HAS FILED AN APPLICATION FOR PLEADING THE FOLLOWING ADDITIONA L GROUND GROUNDS GROUND NO 3: ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LD. ASSESSING OFFICER HAS GROSSLY ERRED IN COMPLETING THE ASSESSMENT UNDER SECTION 143 (3) READ WITH SECT ION 153A/153C OF THE INCOME TAX ACT 1961 EVEN WHEN NO INCRIMINATING THEREBY WHATSOEVER WAS FOUND AS A RES ULT OF SEARCH PERTAINING TO THE YEAR UNDER APPEAL, AND THE ADDITIONS ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 4 HAVE BEEN MADE BY THE LD. AO WITHOUT REFERENCE TO A NY SINGLE MATERIAL FOUND DURING SEARCH THUS CONSEQUENT ORDER PASSED THE DESERVES TO BE QUASHED. GROUND NUMBER 4 : THAT THE LEARNED AO HAS FURTHER ERRED IN MAKING ADDITIONS UNDER SECTION 143 (3) RERAD WITH S ECTIONS 153A/153C BOOTH THE RETURNED INCOME OF THE ASSESSEE WITHOUT REFERRING TO A SINGLE PAPER/INCRIMINATING MATERIAL SEIZED DURING THE COURSE OF SEARCH PARTICULARLY WHEN NO ASSESSMEN T PROCEEDINGS WERE PENDING BEFORE THE LEARNED ASSESSI NG OFFICER AS ON THE DATE OF SEARCH, THEREFORE THE ORDER OF TH E LEARNED AO IS ASKED TO BE HELD BED IN LAW AND THE CONSEQUENT ADDITIONS DESERVES TO BE DELETED. THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSES SEE HAS SUBMITTED THAT THE GROUNDS MAY BE PERMITTED TO BE R AISED BEING LEGAL IN NATURE AND FURTHER GOES TO THE ROOT OF TH E MATTER. IT WAS FURTHER SUBMITTED THAT THERE ARE CATENA OF JUDGEME NTS WHICH PERMIT RAISING OF THE LEGAL GROUNDS AT ANY STAGE AT THIS THE LD DR RAISED OBJECTIONS THAT THE ASSESSEE HAS NOT RAISED THESE G ROUNDS BEFORE THE LD. CIT(A) AND AO, THEREFORE THE LD. CIT(A) AND AO WERE NOT HAVING BENEFIT OF ADJUDICATING THESE ISSUES AT THE TIME OF HEARING. IT WAS FURTHER SUBMITTED THAT EVEN THE GROUND WAS NOT RAIS ED BEFORE THE LD.AO HAS RECORDED DURING THE ORDER PASSED BY THE LD. AO. ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 5 2.2 SINCE THE GROUNDS NO 3-4 WERE RAISED FOR THE F IRST TIME BEFORE US AND IN THE SAID GROUNDS IT HAS BEEN ALLEGED THA T NO INCRIMINATING MATERIAL WAS FOUND AS A RESULT OF SEARCH PERTAINING TO THE YEAR UNDER APPEAL AND THEREFORE, THE ADDITIONS MADE BY THE LD. AO WAS WITHOUT ANY JURISDICTION. IT WAS FOR THAT THE CASE OF THE A SSESSEE THAT THE ASSESSMENT STAND ABATED AS THE RETURN OF INCOME WAS FILED FOR THE YEAR UNDER CONSIDERATION ON24.3.2009. FOR THAT PU RPOSE THE LD. AR RELIED UPON A RECENT JUDGEMENT O F DELHI HIGH COURT IN THE MATTER OF CIT VS. KABUL CHAWLA REPORTED IN 234 TAXMANN 300 ( DELHI) WHEREIN IT HAS BEEN HELD AS UNDER: (25) THE COURT WOULD ALSO LIKE TO REFER TO A JUDGE MENT OF THE KARNATAKA HIGH COURT DATED 25 TH JULY. 2014 IN ITA NO. 38/2014 (M/S CANARA HOUSING DEVELOPMENT COMPANY VS. THE DCI T. THERE THE ASSESSEE, WHICH WAS CARRYING ON REAL EST ATE BUSINESS FILED ITS RETURN OF A.Y.2008-09. HIS CASE WAS TAK EN UP UNDER SECTION 143(3) OF THE ACT AND AN ORDER CAME TO BE P ASSED ON 31 ST DECEMBER, 2010. SUBSEQUENTLY A SEARCH TOOK PLACE IN THE PREMISES OF THE ASSESSEE U/S 132 OF THE ACT ON 12. 04.2011. THE JUDGEMENT NOTES IN THE COURSE OF SEARCH, INCR IMINATING MATERIAL LEADING TO UNDISCLOSED INCOME WAS SEIZED. THE NOTICE WAS ISSUED TO THE ASSESSEE U/S 153A OF THE A CT TO FILE RETURN OF INCOME O N 13TH JANUARY, 2012. EVEN WHIL E THE RETURN WAS UNDER CONSIDERATION, THE CIT INITIATED PROCEEDI NGS U/S 263 OF THE ACT ON THE GROUND THAT THE ORDER PASSED ON 31.12.2010 U/S 143(3) OF THE ACT WAS PREJUDICIAL TO THE INTER EST OF REVENUE. WHEN THE CIT NEGATED THE OBJECTIONS OF THE ASSESSEE TO THE SAID ORDER, THE ASSESSEE APPEALED TO THE ITAT. THE ITAT NEGATED THE PLEA OF THE ASSESSEE THAT BY VIRTUE OF THE PROCEEDINGS INITIATED U/S 153A OF THE ACT, THE ASSE SSMENT FOR SIX YEARS STOOD REOPENED AND IT IS FOR THE ASSESSIN G AUTHORITY TO ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 6 PASS APPROPRIATE ORDER ON THE BASIS OF THE RETURN FILED U/S 153A(1)(A) OF THE ACT. (26) IN THE HIGH COURT THE QUESTION N WAS WHETHER T HE CIT COULD INVOKE THE POWER U/S 263 OF THE ACT ONCE THE PROCEE DINGS U/S 153A WAS INITIATED . THE HIGH COURT IN CANARA HOUS ING DEVELOPMENT (SUPRA) ANSWERED THE QUESTION IN NEGATI VE. IT REFERRED TO THE DECISION OF THIS COURT IN CIT VS. A NIL KUMAR BHATIA (SUPRA) AND CAME TO THE CONCLUSION THAT ONCE THE PROCEEDINGS ARE INITIATED U/S 153A OF THE ACT THE L EGAL EFFECT WAS THAT EVEN WHERE AN ASSESSMENT ORDER IS PASSED, IT WOULD STAND REOPENED. IN THE EYE OF LAW THERE WAS NO ORD ER OF ASSESSMENT. IT MEANT THAT THE AO SHALL ASSESS OR R EASSESS THE TOTAL INCOME OF SIX YEARS. ONCE THE ASSESSMENT IS R EOPENED, THE ASSESSING AUTHORITY CAN TAKE NOTE OF THE INCOME D ISCLOSED IN THE EARLIER RETURN OR WHICH IS NOT UNEARTHED DURI NG THE SEARCH, IN ORDER TO FIND OUT WHAT IS THE TOTAL INCOME OF EACH YEAR AND THEN PASS THE ASSESSMENT ORDER. (27) IT IS IMPORTANT TO NOTE THAT CANARA HOUSING IS ALSO A CASE WHERE SOME MATERIAL WAS UNEARTHED DURING THE SEARCH. FU RTHER, THE HIGH COURT WAS CLEAR THAT ADDITION TO THE INCOME AL READY DISCLOSED WOULD HAVE TO BE BASED ON SOME MATERIAL U NEARTHED DURING THE SEARCH. HIS IS CLEAR FROM THE OBSERVATIO N IN PARA 9 OF THE DECISION TO THE EFFECT. THE AO IS EMPOWERED TO REOPEN THOSE PROCEEDINGS AND REASSESS THE TOTAL INCOME, T AKING NOTE OF THE UNDISCLOSED INCOME, IF ANY, UNEARTHED. DU RING THE SEARCH. IT WAS FURTHER OBSERVED THAT IN THE FACTS OF THAT CASE IF THE CIT HAD COME ACROSS ANY INCOME THAT THE AO HAD NOT TAKEN NOTE OF WHILE PASSING THE EARLIER ORDER , THE SA ID MATERIAL CAN BE FURNISHED TO THE ASSESSING AUTHORITY WHO WILL T AKE NOTE OF IT WHILE DETERMINING TOTAL INCOME. HAVING TAKEN INTO CONSIDERATION THE ABOVE JUDGEME NT , THE HONBLE DELHI HIGH COURT HAS HELD AS UNDER:- ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 7 SUMMARY OF THE LEGAL POSITION ON A CONSPECTUS OF SECTION 153A(1) OF THE ACT READ WITH THE PROVISIONS THERETO AND IN THE LIGHT OF LAW EXPLAINE D IN THE AFOREMENTIONED DECISIONS, THE LEGAL POSITION THAT EMERGES IS AS UNDER:- (I) ONCE A SEARCH TAKES PLACE UNDER SECTION132 OF THE ACT , NOTICE UNDER SECTION153A(1) WILL HAVE TO BE MANDATORILY ISSUED TO THE PERSON SEARCHED REQUIRING HIM TO FILE RETURNS FOR SIX AY IMMEDIATELY PRECEDING TH E PREVIOUS YEAR RELEVANT TO THE AY IN WHICH THE SEAR CH TAKES PLACE. (II) ASSESSMENTS AND REASSESSMENTS PENDING ON THE DATE OF THE SEARCH SHALL ABATE. THE TOTAL INCOME FOR SUC H AYS WILL HAVE TO BE COMPUTED BY THE AOS AS A FRESH EXE RCISE. (III) THE AO WILL EXERCISE NORMAL ASSESSMENT POWER S IN RESPECT OF THE SIX YEARS PREVIOUS TO THE RELEVANT AY IN WHICH THE SEARCH TAKESPLACE. THE AO HAS THE POWER T O ASSESS AND REASSESS THE TOTAL INCOME OF THE AFOREMENTIONED SIX YEARS IN SEPARATE ASSESSMENT O RDERS FOR EACH OF THE SIX YEARS. IN OTHER WORDS THERE W ILL BE ONLY ONE ASSESSMENT ORDER IN RESPECT OF EACH OF THE SIX YEARS IN WHICH BOTH THE DISCLOSED AND THE UNDISCLO SED INCOME WOULD BE BROUGHT TO TAX. (IV) ALTHOUGH SECTION 153A DOES NOT STAY THAT ADDI TIONS SHOULD BE STRICTLY MADE ON THE BASIS OF EVIDENCE F OUND IN THE COURSE OF THE SEARCH, OR OTHER POST SEARCH MATE RIAL OR INFORMATION AVAILABLE WITH THE AO WHICH CAN BE RE LATED TO THE EVIDENCE FOUND, IT DOES NOT MEAN THAT THE ASSESSMENT CAN BE ARBITRARY OR MADE WITHOUT ANY RELEVANCE OR NEXUS WITH THE SEIZED MATERIAL. OBVIO USLY AN ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 8 ASSESSMENT HAS TO BE MADE UNDER THIS SECTION ONLY O N THE BASIS OF SEIZED MATERIAL. (V) IN THE ABSENCE OF ANY INCRIMINATING MATERIAL, T HE COMPLETED ASSESSMENT CAN BE REITERATED AND THE ABA TED ASSESSMENT OR REASSESSMENT CAN BE MADE. THE WORD ASSESS IN SECTION 153 A IS RELATABLE TO ABATED PROCEEDINGS (I.E. THOSE PENDING ON THE DATE OF SEAR CH) AND THE WORD REASSESS TO COMPLETED ASSESSMENT PROCEEDINGS. (VI) IN SO FAR AS PENDING ASSESSMENTS ARE CONCERNE D , THE JURISDICTION TO MAKE THE ORIGINAL ASSESSMENT AN D THE ASSESSMENT UNDER SECTION153A MERGES INTO ONE. ONLY ONE ASSESSMENT SHALL BE MADE SEPARATELY FOR EACH AY ON THE BASIS OF THE FINDINGS OF THE SEARCH AND ANY OTH ER MATERIAL EXISTING OR BROUGHT ON THE RECORD OF THE A O. (VII) COMPLETED ASSESSMENTS CAN BE INTERFERED WITH BY THE AO WHILE MAKING THE ASSESSMENT U/S 153A ONLY ON THE BASIS OF SOME INCRIMINATING ,MATERIAL UNEARTHED DUR ING THE COURSE OF SEARCH OR REQUISITION OF DOCUMENTS OR UNDISCLOSED INCOME OR PROPERTY DISCOVERED IN THE C OURSE OF SEARCH WHICH WERE NOT PRODUCED OR NOT ALREADY DISCLOSED OR MADE KNOWN IN THE COURSE OF ORIGINAL ASSESSMENT. CONCLUSION- THE PRESENT APPEALS CONCERN AYS 2002-03, 2005-06 AND 2006-07, ON THE DATE OF THE SEARCH THE SAID ASSESSMENTS ALREADY STOOD COMPLETED. SINCE NO INCRIMINATING MATERIAL WAS UNEARTHED DURING THE SEA RCH, NO ADDITIONS COULD HAVE BEEN MADE TO THE INCOME ALR EADY ASSESSED. ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 9 2.3 IN THE ABOVE SAID BACKGROUND THE LD. AR HAS SU BMITTED THAT THE ASSESSEE MAY BE PERMITTED TO THE ADDITIONAL GR OUNDS AT THE APPELLATE STAGE. 2.4 WE HAVE HEARD THE PARTIES AND PERUSED THE MATER IAL AVAILABLE ON RECORD. WE ARE IN AGREEMENT THAT THE LD. DR FO R REVENUE THAT THESE GROUNDS WERE NOT RAISED BEFORE THE LOWER AUTH ORITIES AT THE TIME OF ASSESSMENT PROCEEDINGS OR AT THE TIME OF PA SSING OF THE IMPUGNED ORDER BY THE LD. CIT(A). WE ARE OF THE VIE W THAT WHETHER THERE WAS ANY INCRIMINATING EVIDENCE FOUND DURING T HE COURSE OF SEARCH OR NOT IS A QUESTION OF FACT WHICH CAN BE DE CIDED BY THE AO AFTER CONSULTING THE RECORD. IN VIEW THEREOF WE DE EM IT APPROPRIATE TO REMAND THE APPEAL TO THE FILE OF THE AO TO DENO VO CONSIDER THE OBJECTIONS RAISED BY THE ASSESSEE BEFORE US IN THE FORM OF GROUNDS NO. 3 & 4 MORE PARTICULARLY IN THE LIGHT OF THE JUD GEMENT OF DELHI HIGH COURT IN THE CASE OF CIT VS. KABUL CHAWLA (SUP RA). THE ASSESSING OFFICER SHALL EXAMINE THE FACTS OF THE CASE FOR THE PURPOSE OF COMING TO THE CONCLUSION WHETHER THE ASSESSMENT PROCEEDING S STAND ABATED OR NOT AND FURTHER THE ASSESSING OFFICER SHALL EXAM INE THE ISSUE OF INCRIMINATING DOCUMENTS, IF ANY FOUND DURING THE CO URSE OF SEARCH OR NOT . IN VIEW THEREOF THE APPEAL OF THE ASSESSEE I S ALLOWED FOR STATISTICAL PURPOSES. ITA NO. 07/JP/13 SHRI MJS AHLUWALIA, JAIUR VS. THE ACIT, CIRCLE-2, J AIPUR 10 IN THE RESULT THE APPEAL FILED BY THE ASSESSEE IS A LLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 03/06 /2016. SD/- SD/- ( BHAGCHAND ) (LALIET KUMAR) YS[KK LNL;@ ACCOUNTANT MEMBER U;KF;D LNL;@ JUDICIAL MEMBER DATED:- 03/ 06/2016 PILLAI VKNS'K DH IZFRFYFI VXZSF'KR@ COPY OF THE ORDER FORWARDED TO: 1. VIHYKFKHZ@ THE APPELLANT- 2. IZR;FKHZ@ THE RESPONDENT- 3. VK;DJ VK;QDR@ CIT I, JAIPUR 4. VK;DJ VK;QDRVIHY@ THE CIT(A)-I, JAIPUR 5. FOHKKXH; IZFRFUF/K] VK;DJ VIHYH; VF/KDJ.K] T;IQJ@ DR, ITAT, JAIPUR 6. XKMZ QKBZY@ GUARD FILE (ITA NO. 326/JP/2015) VKNS'KKUQLKJ@ BY ORDER, LGK;D IATHDKJ@ ASSISTANT. REGISTRAR